under regulations exactly paralleling UD-ITPA’s definition of business income, patent royalties and mine royalties were business income because they “derived from sources that are integral portions of [taxpayer’s] business”
How later courts described this case
- under regulations exactly paralleling UD-ITPA’s definition of business income, patent royalties and mine royalties were business income because they “derived from sources that are integral portions of [taxpayer’s] business”
Written by the judges who cited it.
The opinion
Appeal from Sup. Ct. Ala. dismissed for want of jurisdiction. Treating the papers whereon the appeal was taken as a petition for writ of certiorari, certiorari denied.